Australian Broadcasting Corporation
submission to
Australian Communication and Media Authority
“Future use of unassigned television channels”
Discussion Paper
April 2006
Australian Broadcasting Corporation submission to the Australian Communication and Media Authority on its Discussion Paper on the
future use of unassigned television channels
Introduction
The ABC welcomes this opportunity to provide comments on the possible use of two 7 MHz television channels that remain unassigned after planning for digital television.
The Discussion Paper seeks comment on the potential uses for and interest in the two unallocated channels set aside in most licence areas by the then-Australian Broadcasting Authority (ABA) for datacasting services. The Paper seeks comment on the possibility of these channels being used for new, non-free-to-air-television services, such as subscription, narrowcasting, data and mobile television services.
In the ABC’s opinion, this unallocated spectrum should instead be used in the first instance to address a number of existing spectrum problems. The ABC believes strongly that the priority order for the use of unallocated television channels should be: first, the provision of multiple transmitter services to meet known reception shortfalls between digital and analog services; secondly, the elimination or reduction of the need for Single Frequency Networks (SFNs) in areas with highly congested spectrum; and, thirdly, where possible, the provision of VHF Band III spectrum for digital radio services.
Correcting existing spectrum problems
A fundamental prerequisite for achieving the switch-off of analog television is public confidence that digital television transmission has an equivalent coverage to the analog service. Without a reasonable expectation that digital television coverage will match the existing analog television coverage, particularly in regional areas, there is little practical likelihood that analog switch-off will be achieved.
To that end, the Corporation has argued in its submission to the January 2005 Review of the Broadcasting Services Band Spectrum: Identification and Structural Efficiency conducted by the Department of Communications, Information Technology and the Arts (DCITA), that the first use for unallocated spectrum, including spectrum reserved for datacasting services, should be the elimination of any existing shortfalls in coverage of digital terrestrial
television. Such coverage shortfalls can arise when digital services are introduced using UHF spectrum in areas where the corresponding analog services are carried on VHF channels.
The principle needs to be recognised that achieving equivalent coverage for an analog service may require a number of digital transmitters or services. The ABC’s submission to DCITA highlighted these issues with a discussion of the move from analog on VHF to digital
1
ABC COMMENTS ON THE USE OF UNASSIGNED CHANNELS 2
on UHF in the Bega/Cooma region and sought government leadership in the resolution of these issues in a way that does not disadvantage viewers or demand excessive expenditure by broadcasters.
During the original digital channel planning for digital terrestrial television services, the then-ABA acknowledged that delivering digital coverage equivalent to existing analog services required two translators for each digital service to replace the corresponding analog service. However, as the need to provide spectrum for datacasting channels became an important priority, this planning requirement was discarded in favour of the assumption that it would be possible to deliver equivalent coverage with the same number of digital transmitters as were used for analog services. As a consequence, many known limitations on achieving equivalent coverage to analog television with digital transmissions remain
unaddressed. The full extent of these shortfalls will not become clear until analog switch-off is completed, as a result of the number of digital transmitters that are not operating on full power due to interference issues.
The second use for unallocated channels should be addressing problems created by SFNs in some areas. As the ABC has previously indicated, it does not consider SFNs to have been successful, as they cannot achieve equivalent coverage to analog services and have given rise to a high level of transmission-related complaints in certain areas where they are used.
Accordingly, the Corporation is opposed to the planning of SFNs.
As previously argued in its submission to the DCITA review of broadcasting services band (BSB) spectrum, the ABC believes this is particularly true of the two unallocated channels set aside for datacasting, the reservation of which was one of the key reasons for the adoption of SFNs in areas such as the Central Coast of New South Wales and the Gold Coast and the Sunshine Coast in Queensland. As described in detail in the ABC’s BSB spectrum
submission, digital television audiences in those areas have suffered from “mush area”
interference problems as a result.
Finally, the ABC believes that, where spare VHF Band III spectrum is available, it should be used to ensure adequate spectrum is made available for Digital Audio Broadcasting digital radio services. This is particularly important in light of the Minister’s recent announcement that digital radio broadcasting will commence in the mainland capital cities from 1 January 2009.1
New digital services
While the ABC believes that the channels currently reserved for datacasting services should be used to address existing problems with digital television in Australia, it acknowledges
1 Senator the Hon. Helen Coonan, Minister for Communications, Information Technology and the Arts. “Digital Radio to be introduced by 2009”, Media Release, 4 April 2006.
that this is not the approach taken in the Discussion Paper or in the Government’s recent discussion paper on media reform options, Meeting the Digital Challenge: Reforming Australia’s Media in the Digital Age. The Corporation thus offers the following comments on possible new uses for the spectrum.
The ABC is strongly of the view that any new services that are to be introduced using BSB spectrum need to be planned on the same rigorous basis as is currently employed for broadcasting services, including recognising the need to protect analog and other digital services from interference. As such, broadcasting services that may deliver video to mobile devices need to be based on models involving high-powered central transmission facilities, which is likely to entail locating transmitters in the same general areas as transmitters for existing terrestrial services to reduce the level of potential interference.
The Paper acknowledges the Government’s stated intention of extending the existing prohibition on the national broadcasters controlling datacasting transmitter licences. As the ABC argued in its submission to DCITA on media reform options, the Corporation is unsure whether this restriction is desirable in light of the Government’s broader objective of
removing cross-media and other regulatory barriers. Further, if the intent of continuing this restriction is to ensure the emergence of new services using the currently unallocated spectrum, the ABC points to its record as an innovator and enabler of new digital services.
Notwithstanding this, the Corporation notes that there is nothing in this restriction to prevent the ABC from providing content to operators of transmitter licences, including for datacasting and mobile television services.
Mobile television
In the case of future mobile television services, the ABC believes that there is likely to be a case for mandating access to a certain percentage of the spectrum for the national
broadcaster to ensure that quality Australian content is able to be accessed by Australians through these new services. There is every reason to believe that the Australian public will regard mobile television services as an extension of existing television broadcasting and will expect ABC services to be available to them. Like all broadcasting services, there should be sectoral diversity in the selection of content made available to viewers over mobile television services. Similarly, the ABC would expect that this new form of broadcasting service would be subject to the same end-to-end planning processes as other services operated in BSB spectrum, both to ensure that consumers enjoy a service consistent with their existing expectations of television broadcasting and to protect services in adjacent bands from interference.
The ABC is currently involved in providing content for both the datacasting and the mobile television trials and notes that most content providers for the mobile television trials are subscription television channels that carry minimal Australian content. Access could be
ABC COMMENTS ON THE USE OF UNASSIGNED CHANNELS 4
mandated for the ABC to provide a channel of short-form Australian information and other local video content suitable for this new portable broadcasting platform.
Datacasting services
The ABC believes that there are a number of possible new, interactive digital-only services that would provide rich viewer experiences and would further assist with the uptake of digital television in this country. The ABC has explored a number of ideas for datacasting services of this kind, including education and regional news and information services, that it is unable to mount as inadequate space remains on its existing 7 MHz broadcasting spectrum allocation. The Corporation would be potentially interested in offering such services if
further spectrum became available, either on a datacasting multiplex operated by the holder of a datacasting transmitter licence or if the Corporation was itself able to secure control of such a licence.
Completing digital roll-out
Once the Government’s Digital Action Plan establishes a firm date for analog switch-off, the ACMA should begin actively planning spectrum arrangements for that event. The full planning for digital services after the closure of analog services needs to be completed as soon as possible. This will provide certainty to broadcasters and transmission service providers and allow for future planning of transmission infrastructure.
Such planning should include the digitisation of self-help services, which to date continue to be planned in analog. In accordance with the principle of universal coverage, the ABC plans and expects to offer the full range of its digital services in self-help areas, including ABC2, an electronic program guide, interactive programming elements, high definition television (HDTV) broadcasts required under legislation and radio services, such as dig. Additionally, it might include the planning of further spectrum for the ABC if the number or minimum technical standards applying to the services that it is required to provide are increased.
Digital Dividend
The Discussion Paper requests comments on the potential rearrangement and rationalisation of channels following the cessation of analog television broadcasting to deliver a “digital dividend” in the form of additional spectrum that can be used for other purposes.
The ABC would like to remind the ACMA that the cost of reassigning spectrum within the existing BSB after the closure of analog services will come at a significant cost for both
viewers and broadcasters. Any changes in the frequency on which services are broadcast will involve significant investment by broadcasters, as they will require a number of costly
alterations to transmission infrastructure, including the replacement of combiners and other equipment for UHF band channels and the replacement of channel-specific antennas in the VHF bands.
The ABC notes that the existing spectrum problems outlined above for which additional channels are required are unlikely to be entirely solved even if the channels currently set aside for datacasting services are applied to this purpose. The first priority in assigning spectrum freed up by the full transition to digital television broadcasting should be the solution of these problems.
